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	==See also==		==See also==
	~~{{Portal\|Indiana}}~~
	* [[History of slavery in Indiana]]		* [[History of slavery in Indiana]]
	* [[Indiana Supreme Court]]		* [[Indiana Supreme Court]]

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{{Short description|Enslaved woman in the US Northwest Territory (c. 1796–unknown)}}
{{Infobox person
| honorific_prefix =
| name = Polly Strong
| image = Drawing of Polly Strong.png
| alt = Drawing of Polly Strong, who sued for her freedom in 1820, Indiana
| caption = Drawing of Polly Strong, who sued for her freedom in 1820, Indiana
| birth_name = 
| birth_date = ca. 1796 
| birth_place = [[Northwest Territory]]
| death_date = Unknown 
| death_place =
| resting_place =
| resting_place_coordinates = 
| nationality =
| known_for = ''[[Indiana Supreme Court#Landmark cases|State v. Lasselle]]'', [[Supreme Court of Indiana]] [[freedom suit]] case
| spouse =
}}
'''Polly Strong''' (circa 1796–unknown) was an enslaved woman in the [[Northwest Territory]], in present-day Indiana. She was born after the [[Northwest Ordinance]] prohibited slavery. Slavery was prohibited by the [[Constitution of Indiana]] in 1816. Two years later, Strong's mother Jenny and attorney Moses Tabbs asked for a [[writ]] of ''[[habeas corpus]]'' for Polly and her brother James in 1818. Judge [[Thomas H. Blake]] produced indentures, Polly for 12 more years and James for four more years of servitude. The case was dismissed in 1819.

In 1819, attorneys John W. Osborn and [[Amory Kinney]], sought to test the legality of slave arrangements made prior to 1816. They sued for Strong's freedom at the Knox County Circuit Court in ''Polly v. Lasselle'' in 1820, but the court ruled that she was to remain enslaved. The case was appealed to the [[Indiana Supreme Court]] in ''State v. Lasselle''. Based upon the 1816 [[Constitution of Indiana]], the justices ruled that "slavery can have no existence" in Indiana. Strong was freed. Other enslaved people were not automatically freed, but there was a precedent that others could use in the courts. In 1821, the ''[[Mary Bateman Clark#Court cases|Mary Clark v. G.W. Johnston]]'' case was tried in the Indiana Supreme Court, which ruled that indentured servitude was no longer legal in Indiana. The number of enslaved people reduced over the next couple of decades. There were three slaves in the state in both the 1830 and 1840 censuses.

==Background==
[[File:Natives guiding french explorers through indiana.jpg|thumb|Native Americans guiding French Explorers through Indiana, ''Stories of Indiana'', by [[Maurice Thompson]]]]
By 1746, African and Native American enslaved people were owned by Catholic priests and French traders, and the practice continued during the period when Great Britain controlled the area that is Indiana. The frontier north and west of the [[Ohio River]] became the [[Northwest Territory]] in 1787. Article VI of the [[Northwest Ordinance]] prohibited slavery and involuntary servitude. Many slaveholders took this to mean that the ordinance excluded people who already owned slaves.<ref name="IN gov" />{{efn|President of the Congress [[Arthur St. Clair]] (and later governor) told residents that the provision did not free enslaved people who lived in the territory before 1847. The first territorial judge, George Turner disagreed with St. Clair and issued an order granting freedom to slaves of Judge Henry Vanderburgh, Peter and Queen McNelly.<ref name="McCormick" />}}

[[File:Northwest-territory-usa-1787.png|thumb|left|Map of the [[Northwest Territory]] as of 1787, with years of statehood]]
In 1800, the [[Indiana Territory]] was formed.<ref name="IN gov" /> Many slaveholders immigrated to the territory bringing their slaves with them. The territory passed legislation that allowed for the slaves to be [[indentured servitude|indentured]] within the territory. This law allowed slaveholders to continue in their ownership of slaves that were purchased outside of the state, even if the slaves came to reside in Indiana.<ref name= dunn346>Dunn, p. 346</ref>

Slavery and involuntary servitude were prohibited by the 1816 [[constitution of Indiana|Indiana Constitution]].<ref name="IN gov" /> This ban brought the previous laws that had permitted slavery into conflict, and the issues of whether preexisting slave arrangements were still legal was brought before the courts on several occasions. Each time the circuit courts had denied or approved the freedom of the slaves on an individual basis.<ref name= dunn346/> Black people continued to remain enslaved or indentured servants after 1816. There were 190 slaves in Indiana in 1820, 118 of them in [[Knox County, Indiana]].<ref name="IN gov" />

In his article “Almost a Free State", historian [[Paul Finkelman]] enumerated three ways for enslaved people in Indiana to become free. They could runaway, they could hire attorneys to file [[freedom suit]]s in the court, or their owners could decide to give them their freedom.<ref name="IN gov" />

==Early life==
Around 1796, Polly Strong was born in the [[Northwest Territory]] to an enslaved woman, Jenny, who was owned by Antoine Lasselle who lived near [[Fort Wayne]]. Her father was someone with the surname of Strong. Prior to Strong's birth, Jenny, had been kidnapped by Native Americans. She was sold to Antoine Lasselle after the [[Treaty of Greenville]] (1795). Strong's brother, James, was born around 1800. They were separated when Strong was sold to Joseph Barron. James was later sold to someone with the surname of LaPlante.<ref name="IN gov" />{{efn|Jean LaPlant was a slaveholder at the time.<ref name="McCormick" />}} At around the age of ten, Strong was purchased by Hyacinthe Lasselle, an innkeeper and trader from [[Vincennes, Indiana|Vincennes]], in what was then [[Indiana Territory]] (1800–1816). Lasselle later purchased James.<ref name="IN gov" />

Strong was baptized on April 11, 1819, with the name Marguerite at the St. Francis Xavier Catholic Church in Vincennes. At the time, she was identified as a mixed-race woman.<ref name="IN gov" /> She may not have been treated well by Lasselle. Strong was described as pretty with a "bright disposition" and "pleasing manners".<ref name="ECP" />

Strong and her brother were threatened by Lasselle and imprisoned after the writ of ''habeas corpus'' was filed.<ref name="IN gov" /> She sought asylum and was taken in by Joseph Huffman, an African American barber, on January 9, 1820. A grand jury indicted Huffman for "harboring a servant girl" on February 10.<ref name="McCormick" /> Huffman paid for a $200 ({{inflation|US|200|1820|fmt=eq}}) appeal bond for her release from Lasselle.<ref name="McCormick" />

==The Lasselles==
The Lassalles were among the oldest family of immigrants in the state and had been in the region since [[Kingdom of France|France]] had owned it in the 18th century.<ref name = dunn347/>{{efn|Hyacinthe Lasselle's father was Jacques Lasselle, a French-Canadian trader from [[Montreal]]. Jacques traded with Native Americans at [[Detroit]], [[Kekionga]], and [[Fort Wayne]].<ref name="IN gov" /> Around 1765, Jacques married a [[Miami Tribe|Miami]] woman.<ref name = dunn347/> He had four sons, including Hyacinthe (1777–1843), who also became traders. Antoine Lasselle was Lasselle's uncle.<ref name="IN gov" />}} Hyacinthe Lasselle settled in Vincennes in 1804, where he was appointed to legislative and civic positions. He operated an inn, a bar, and a distillery and fought during the [[War of 1812]].<ref name="IN gov" /> Vincennes had been an early outpost for the French, who bought slaves to tend to their "creature comforts".<ref name="ECP" /> Lasselle purchased his slaves from Native Americans, and when the state constitution was enacted, he made a show of freeing his slaves, but they were not really freed.<ref name="ECP" />

==Court cases==

===Writ of ''habeas corpus''===
Although slavery was prohibited by the [[Indiana Constitution]] of 1816, Strong remained enslaved. Moses Tabbs, an attorney who worked with her mother Jenny, asked the Knox County Circuit Court for a [[writ]] of ''[[habeas corpus]]'' for Jenny, Strong (22) and her brother James (15) on July 15, 1818.<ref name="IN gov" /><ref name="McCormick" /> Lasselle was forced to court to show why Jenny's two children should remain enslaved.<ref name="IN gov" /> On August 4, 1818, Judge [[Thomas H. Blake]] met in his chambers with Laselle, Strong, and James.<ref name="McCormick" /> He produced indentures, Strong for 12 more years and James for four more years of servitude. Before a local [[justice of the peace]], Strong and James acknowledged that their indentures to Lasselle were voluntary.<ref name="IN gov" /> During this time, Strong and James were threatened by Lasselle and imprisoned when the indentures were signed.<ref name="IN gov" /> The case of ''James and Polly vs. Laselle'' was dismissed without prejudice in May 1819.<ref name="McCormick" /> James no longer appeared in ''habeas corpus'' cases after that.<ref name="McCormick" />

===''Polly v. Lasselle''===
In 1819, two [[Abolitionism in the United States|abolitionist]]s, John W. Osborn and [[Amory Kinney]], sought the aid of a [[Vincennes, Indiana|Vincennes]] law office to test the legality of slave arrangements made prior to 1816. The two were [[Canada|Canadians]] who had immigrated to Indiana after the [[War of 1812]]. They believed that the constitutional ban on slavery extended to all slaves, including those held before 1816. The lawyers at the office, Colonel George McDonald and Moses Tabbs, also members of the anti-slavery party, began to prepare a test case to bring before the courts.<ref name="dunn347">Dunn, 347</ref> Strong had been purchased before the Northwest Territory had been established, and if she could be freed then a precedent would be set whereby all other slaves in the state could also be set free.<ref name = dunn347/> Her case had been combined with a similarly situated enslaved man, Francis Jackson, who was owned by Francoise Tisdale.<ref name="McCormick" />

On January 27, 1820, attorney Amory Kinney filed a [[freedom suit]] on her behalf with the Knox County Circuit Court.<ref name="IN gov" /><ref name="McCormick" /> Lassalle's defense attorney was Judge [[Jacob Call]], a future [[Congressman]].<ref name = dunn347/>

The circuit court in Vincennes ruled that Strong should remain a slave in part because Polly's mother was a slave before the Northwest Ordinance of 1787 was passed, so they found that her mother remained a slave. Slaveholders in slave states automatically owned any of their enslaved women's children under ''[[ partus sequitur ventrem]]'' and the judges ruled that doctrine should apply to this case as well.<ref name="Williams SB" />

===''State v. Lasselle''===
[[File:Seal of the Indiana Supreme Court.jpg|thumb|right|Seal of the Indiana Supreme Court]]
The appeal was filed by Kinney to the [[Indiana Supreme Court]] in [[Corydon, Indiana]] on May 12, 1820.<ref name="IN gov" /> Representing Strong were Amory Kinney, Col. George McDonald, and Moses Tabbs.<ref name="Williams SB" /> John W. Osborn, Kinney's law partner, was also involved in the case.<ref name="dunn347"/><ref name="Williams SB" /> In June 1820, the case was appealed to the [[Indiana Supreme Court]]. [[List of justices of the Indiana Supreme Court|Chief Justice]] [[Isaac Blackford]] was the son-in-law of McDonald, one of the [[plaintiff]]'s lawyers. The plaintiff's lawyers argued that the constitution superseded all other laws, including one written prior to the constitution's adoption, and that the Northwest Ordinance ceased to apply to Indiana after statehood. The defense argued that the Northwest Ordinance, a federal law, superseded the state constitution and that it could have been repealed only by the federal government but was not repealed, it was still in effect regardless of Indiana's status in the Union.<ref name = dunn347/><ref name="Lasselles opinion">{{cite web|url=http://www.in.gov/judiciary/citc/special/bound-for-freedom/lasselle-opinion.pdf|author=Indiana Supreme Court|author-link=Indiana Supreme Court|publisher=IN.gov|date=July 1820|access-date=2008-07-06|title=The State v. Lasselle|archive-url=https://web.archive.org/web/20080721195500/http://www.in.gov/judiciary/citc/special/bound-for-freedom/lasselle-opinion.pdf|archive-date=2008-07-21}}</ref>

The ruling was made on July 22, 1820,<ref name="IN gov" />
based upon the Indiana Constitution, 11th article, section 7,
{{quote|There shall be neither slavery nor involuntary servitude in this state, otherwise than for the punishment of crimes, whereof the party shall have been duly convicted. Nor shall any indenture of any negro or mulatto hereafter made, and executed out of the bounds of this state be of any validity within the state."<ref name="Williams SB" />}}

Justice [[James Scott (judge)|James Scott]] wrote, "It is evident that by these provisions, the framers of our constitution intended a total and entire prohibition of slavery in this State; and we can conceive of no form of words in which that intention could have been more clearly expressed."<ref name="Williams SB" /> Strong was declared a free woman.<ref name="Timeline" />

Lasselle filed an appeal with the [[Supreme Court of the United States]] on July 27, 1820. The court refused to hear the case, upholding the decision made by the Indiana Supreme Court.<ref name="USSC" />

===Decision repercussions===
The decision was a major victory for the abolitionists in the state who had organized to ban slavery only seventeen years earlier.<ref>Dunn, p. 253</ref> Strong was free, but the decision did not free other enslaved people. However, it made the Indiana Constitution the authority for decisions regarding slavery and involuntary servitude in Indiana courts.<ref name="IN gov" />

There was some anger among the slaveholding community and violence was threatened against Osborn and Kinney, but no action was taken against them. The case also led to the impeachment of the [[Clark County, Indiana|Clark County]] [[Justice of the Peace]] for aiding slaveholders who refused to free their slaves. Many slaveholders, not wanting to lose their valuable slaves, left the state before their slaves could be taken from them.<ref>Dunn, p. 348</ref>

The 1820 [[US census]] revealed that there were 190 slaves in Indiana and 1,200 free blacks. The number of slaves dropped off dramatically and there were only three slaves in the state in both the 1830 and 1840 censuses.<ref>{{cite web
|url = http://fisher.lib.virginia.edu/collections/stats/histcensus/php/newlong.php
|title = Total Slave Population in US, 1790–1860, by State
|access-date = 2007-12-28
|url-status = dead
|archive-url = https://web.archive.org/web/20070822165604/http://fisher.lib.virginia.edu/collections/stats/histcensus/php/newlong.php
|archive-date = 2007-08-22
}}</ref>

In 1821, Kinney filed a suit to free an indentured servant, [[Mary Bateman Clark]]. As with Strong's case, Clark lost in the Circuit Court, but appealed the decision with the Indiana Supreme Court, where they won. This was a landmark case for indentured servants and foretold the end of [[wikt:bondservant|bondservants]] in Indiana.<ref name="IBC">{{Cite web |title=Mary Bateman Clark Project |url=https://www.in.gov/ibc/legacyprojects/2770.htm |access-date=2022-02-21 |website=Indiana Bicentennial Commission, Indiana state government}}</ref>

==Later life==
On March 2, 1822, Joseph Huffman sued Strong to collect money that he lent her. Strong was arrested, and bail was set and paid six days later. Strong denied the charges, but the jury found in favor of Huffman and awarded him $35 in damages.<ref name="Timeline" />

One report is that Strong moved to [[St. Louis]], [[Missouri]] and later traveled to Indiana where she visited members of the Lasselle family.<ref name="ECP" /> In a June 17, 1825 letter to Lasselle, her brother James promised to deliver Strong's bureau when requested. This is the last known direct reference to Strong. In the 1830 U.S. Federal Census, there is a woman of her age in residence with Lasselle. In 1833, Lasselle moved to [[Logansport, Indiana]], where he died in 1843.<ref name="Timeline" />

==Legacy==
[[File:Corydon old capital.jpg|thumb|[[Old Capitol (Indiana)|First State Capitol building]] in downtown [[Corydon, Indiana]]]]
A historical marker commemorating Polly Strong is located in front of the [[Harrison County Courthouse (Indiana)|Harrison County Courthouse]] and the [[Old Capitol (Indiana)|First State Capitol building]] in [[Corydon, Indiana]].<ref name="IN gov" />

==See also==
{{Portal|Indiana}}
* [[History of slavery in Indiana]]
* [[Indiana Supreme Court]]
* [[American slave court cases]]

==Notes==
{{Notelist}}

==References==
{{reflist | refs=
<ref name="ECP">{{Cite news |date=1899-05-04 |title=How Slavery Once Existed in Indiana |pages=3 |work=Evansville Courier and Press |url=https://www.newspapers.com/clip/95550819/how-slavery-once-existed-in-indiana/ |access-date=2022-02-19}}</ref>

<ref name="IN gov">{{cite web | url=https://www.in.gov/history/state-historical-markers/find-a-marker/find-historical-markers-by-county/indiana-historical-markers-by-county/polly-strong-slavery-case/ | title=Polly Strong Slavery Case | date=15 December 2020 | publisher=State of Indiana | accessdate=February 19, 2022 }}</ref>

<ref name="McCormick">{{Cite news |last=McCormick |first=Mike |title=Historical Perspective: Revisiting the Struggles of Polly Strong |language=en |work=Tribune-Star |url=https://www.tribstar.com/news/lifestyles/historical-perspective-revisiting-the-struggles-of-polly-strong/article_86150825-8d63-594b-baca-b0e04080a032.html |access-date=2022-02-19}}</ref>

<ref name="Timeline">{{Cite web |title=Bond for Freedom Timeline |url=http://www.in.gov/judiciary/citc/special/bound-for-freedom/timeline.pdf |archive-url=https://web.archive.org/web/20080721195506/http://www.in.gov/judiciary/citc/special/bound-for-freedom/timeline.pdf |archive-date=2022-02-19 |website=Indiana state government}}</ref>

<ref name="USSC">{{Cite web |last=Lasselle |first=Hyacinthe |title=U.S. Supreme Court assignment of errors in Polly v. Lasselle, 1820 July 27 |url=http://indianamemory.contentdm.oclc.org/cdm/ref/collection/p16066coll38/id/26 |access-date=2022-02-20 |website=Indiana State Library Digital Collections}}</ref>

<ref name="Williams SB">{{Cite journal |last=Williams |first=Sandra Boyd |year=1997 |title=The Indiana Supreme Court and the Struggle Against Slavery |journal=Indiana Law Review |series=Symposium: The History of Indiana Courts: People, Legacy and Defining Moments |volume=30 |issue=1 |pages=307–310 |doi=10.18060/3223|doi-broken-date=31 December 2022|url=https://journals.iupui.edu/index.php/inlawrev/article/view/3223 }}</ref>
}}

==Bibliography==
* {{cite book|title=Indiana and Indianans|url=https://archive.org/details/indianaindianans01indunn|author= Dunn, Jacob Piatt|publisher=American Historical Society|year=1919}}'

==Further reading==
* Dani Pfaff, "Let the Records Show: Slavery and Involuntary Servitude in Vincennes, Indiana," ''Traces of Indiana and Midwestern History'', v. 24, no. 2, Indianapolis:Indiana Historical Society, 2012, pp. 36–41.

==External links==
* [https://web.archive.org/web/20080720054614/http://www.in.gov/judiciary/citc/special/bound-for-freedom/index.html Bound for Freedom – articles on the case from the Indiana Court System], includes full text opinion

{{Indiana history}}

{{Authority control}}

{{DEFAULTSORT:Strong, Polly}}
[[Category:1790s births]]
[[Category:Date of death unknown]]
[[Category:18th-century American slaves]]
[[Category:19th-century American slaves]]
[[Category:People of the Northwest Territory]]
[[Category:19th century in the Northwest Territory]]
[[Category:19th-century American people]]
[[Category:19th-century African-American women]]
[[Category:Freedom suits in the United States]]
[[Category:Indiana state case law]]
[[Category:Legal history of Indiana]]
[[Category:1820 in United States case law]]
[[Category:United States slavery case law]]
[[Category:1820 in Indiana]]
[[Category:Vincennes, Indiana]]
[[Category:African-American history of Indiana]]

Polly Strong - Revision history

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